Barbara McNorton Hovell v. Origin Bank F/K/A Community Trust Bank

CourtLouisiana Court of Appeal
DecidedSeptember 23, 2020
Docket53,527-CA
StatusPublished

This text of Barbara McNorton Hovell v. Origin Bank F/K/A Community Trust Bank (Barbara McNorton Hovell v. Origin Bank F/K/A Community Trust Bank) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barbara McNorton Hovell v. Origin Bank F/K/A Community Trust Bank, (La. Ct. App. 2020).

Opinion

Judgment rendered September 23, 2020. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 53,527-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

BARBARA McNORTON HOVELL Plaintiff-Appellant

versus

ORIGIN BANK F/K/A Defendant-Appellee COMMUNITY TRUST BANK

Appealed from the Fourth Judicial District Court for the Parish of Ouachita, Louisiana Trial Court No. 2016-2046

Honorable Wilson Rambo, Judge

OFFICE OF DONALD L. KNEIPP Counsel for Appellant, By: Donald L. Kneipp Robert H. Holladay

WOOD LAW FIRM Counsel for Appellee By: R. Douglas Wood, Jr.

HAYES, HARKEY, SMITH, & CASCIO By: Thomas M. Hayes, III

Before WILLIAMS, GARRETT, and THOMPSON, JJ. THOMPSON, J.

This appeal arises from the trial court’s granting of an exception of no

cause of action against a seller of a broadcast radio station by the bank who

provided financing for the buyer. The relatively low threshold consideration

for overcoming an exception of no cause of action is if the petition states a

cause of action on any ground or portion of the demand. Plaintiff has set

forth a potential cause of action in his pleadings, and we therefore reverse

and remand the matter for further proceedings.

SUMMARY

The applicable parties in this matter are the owner/seller of a

broadcast radio station, the buyer, and the bank funding the purchase. The

absence of various security interests inuring to the benefit of a subrogee of

the bank’s position is at the crux of the dispute. When the buyer stopped

making installment payments on the loan, the bank seized a guarantor’s

certificate of deposit (“CD”), which had been pledged as security for the

loan. The seller was ultimately revealed to be the source of the funds for the

CD.

A seller may owner-finance the sale of a radio broadcast station, but

Federal Communication Commission (“FCC”) rules prohibit a seller from

retaining a reversionary interest in the FCC broadcast license.1 A broadcast

license can have significant value and was one of the assets being conveyed

in the present sale. The parties elected for the buyer to obtain a commercial

loan. When the buyer was apparently unable to obtain independent

financing, the seller, using a third party to disguise the actual source of the

1 See 47 C.F.R. § 73.1150. funds, deposited the funds in a CD with the lending bank. The CD was in an

amount equivalent to one hundred percent (100%) of the amount sought to

be borrowed by purchaser. With that collateral, the bank provided the buyer

with financing, the sale concluded, and the buyer began making regular

monthly installments on the loan.

A few years later, the buyer stopped paying the monthly installments

on the loan, and with the loan in arrears, the bank began deducting the

payment amounts from the pledged CD. After subsequent delinquent

payments, the bank seized the entire remaining loan balance due and

returned the balance of the funds in the CD to seller.

The seller, now subrogated to the position of the bank, sought

recovery from the borrower, who was the buyer, of its seized funds and filed

suit against that buyer. During that process, the seller discovered the bank

had not secured a personal guaranty from the buyer, an interest in the FCC

broadcast license, or an interest in the furniture, fixtures, and equipment that

comprised a part of the sale. The seller has alleged that when the bank was

discussing the pledge of the CD with seller’s undisclosed representative, the

bank made verbal promises to obtain additional security, including a

personal guaranty from the buyer and the seller and to file liens against the

assets of the radio station being conveyed. The bank denies those

allegations.

The seller asserts that the bank owed a duty of good faith and fair

dealing in connection with obtaining the additional security, despite there

being no written document to support seller’s claims. The bank asserts that

there is no writing memorializing any agreement to obtain additional

2 security on the loan and that it had no duty to obtain any of the security the

seller alleges was promised to his undisclosed agent. The bank undertook its

usual and customary underwriting in order to determine whether to offer a

loan to the buyer and then obtained the security it deemed appropriate to

support its lending decision.

The seller then filed suit against the bank for the alleged breach of the

duty of good faith and fair dealing, which he asserts resulted in damages.

The bank filed an exception of no cause of action against the seller, and the

trial court granted the exception. The seller now appeals that judgment.

FACTS AND PROCEDURAL HISTORY

On March 4, 2011, Holladay Broadcasting of Louisiana, LLC, owned

and operated by Robert H. Holladay (“Holladay”), sold a radio station to KP

Music Group, LLC (“KP Music”), for $700,000. KP Music financed the

purchase of the radio station through Origin Bank F/K/A Community Trust

Bank (“Origin”) and executed two promissory notes dated March 2, 2011, to

Origin, one for $50,000 in operating capital and the other for the $700,000

purchase price.

Origin required collateral for the notes in favor of KP Music. Original

plaintiff in this action, Barbara McNorton Hovell (“Hovell”), pledged a

certificate of deposit in the amount of $750,000, after replacing another

woman who originally pledged the funds necessary to secure the loan.

Hovell is Holladay’s former mother-in-law. Hovell executed two

assignments of deposit account in favor of Origin dated April 11, 2011,

wherein she assigned a CD worth $750,000 to secure the promissory notes in

favor of KP Music. Holladay alleges that Origin verbally agreed to secure

3 additional collateral for KP Music’s loan, specifically including: 1) a UCC

financing statement on the furniture, fixtures, and equipment belonging to

the radio station owned by KP music, 2) a lien on KP Music’s FCC License,

3) a personal guaranty from Holladay, and 4) a personal guaranty from

Calvin H. Murry (the owner/operator of KP Music). The record contains no

writing that reflects any such assertion by Origin Bank, and neither party has

referred to any such writing.

Approximately four years after the purchase of the radio station and

systematically paying the monthly installments as they came due, KP Music

stopped making monthly payments in 2015. Origin sent Hovell written

notification via certified mail that KP Music had missed a monthly payment

and informed her that the monthly payment had been deducted from her CD,

in accordance with the security agreement. In July 2015, after additional

monthly payments were not made by KP Music, Hovell was notified that

Origin had seized and liquidated the CD to satisfy the balance of KP Music’s

loan. The balance of the CD in excess of the loan balance was returned to

Hovell.

On June 30, 2016, after alleged unsuccessful efforts to recover funds

from KP Music in a separate lawsuit, Hovell, acting through her agent and

attorney in fact, Holladay, filed a petition for damages against Origin.

Hovell argued in her petition that because Origin liquidated her CD, she was

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Barbara McNorton Hovell v. Origin Bank F/K/A Community Trust Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barbara-mcnorton-hovell-v-origin-bank-fka-community-trust-bank-lactapp-2020.